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of <h1>Entertainers' and athletes' income may be taxed where activities occur, except when funded by home State's public funds.</h1> Income earned by entertainers and athletes from personal activities in a Contracting State may be taxed in that State, regardless of Articles 13 and 14. If the income accrues to another person, it can still be taxed in the State where the activities occur. However, if the entertainer or athlete's activities are funded wholly or substantially by public funds from their resident State, the income is taxable only in that State. Similarly, if income accrues to another person supported by public funds from the other State, it is taxable only in that State.
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